Comment in Opposition to the Proposed Rescission of EEO Reporting requirements

Re: Notice of Proposed Rulemaking, “Removal of Reporting Requirements,” Docket RIN 3046-AB37, published July 23, 2026

Submitted August 19, 2026

The Boston Women's Workforce Council (BWWC) writes to oppose the Equal Employment Opportunity Commission's proposed rule to rescind EEO-1, EEO-2, EEO-3, EEO-4, EEO-5, and EEO-6 reporting and recordkeeping requirements. We submit this comment as an organization that has witnessed remarkable change due to similar reporting the Commission now proposes to dismantle, and we ask the Commission to withdraw the proposed rule. 

Who we are

The BWWC is a public-private partnership between the Boston Mayor and Greater Boston employers dedicated to eliminating gender and racial wage gaps. We do so by measuring, analyzing, and reporting on these gaps, and by working for over a decade with more than 200 employers committed to wage gap elimination. Through our flagship Wage Gap Measurement Program, employers submit anonymized payroll data to create a community-wide snapshot of progress toward pay equity that no single employer could produce alone. Our data collection process is made completely confidential by using Multi-Party Computation software developed by Boston University data scientists.

The BWWC model exists because the EEOC proved decades ago that comprehensive workforce demographic reporting can help identify and remedy gaps in the workplace. Our work is a complement to federal reporting, built on the same premise: employers cannot close a gap they cannot see. Consistent, comparable data makes wage gap identification possible.

Our results show what data collection can accomplish.

In our most recent measurement cycle, participating employers achieved a 42% reduction in the gender wage gap. That was no accident. It happened because employers had access to clear, recurring metrics that they could use as industry benchmarks, creating accountability both internally and externally. Employers use the data to identify pay disparities, adjust salaries, audit promotion pipelines, and set concrete targets for the next cycle.

The EEOC data serves audiences the rule does not consider

The proposed rule frames EEO reporting almost entirely as a transaction between employers and the Commission. That framing leaves out most of the people who rely on this data. Regional pay equity coalitions like ours use EEO-1 data as a reference point. Academic researchers rely on EEO-1 microdata to study occupational segregation and the effectiveness of interventions like ours. Employers from all sectors use the data to understand their own competitiveness when it comes to hiring and retaining talent. All of these users depend on the EEO data being collected.

Our recommendation

We ask the Commission to withdraw this proposed rule. If the genuine concern is administrative burden or an outdated form, we would support rulemaking that modernizes the EEO reports rather than eliminates them, like simplifying categories or further digitizing filing options.

If the Commission proceeds, we ask that it preserve, at minimum, the underlying recordkeeping requirements, so employers retain the ability to produce this data voluntarily or in response to state-level requirements like those we rely on in Massachusetts.

BWWC's work, and the significant reduction in the gender wage gap our members have achieved, exists because employers are willing to participate in workforce data collection. The EEOC's own reporting requirements built the template for that support. Removing reporting requirements destroys the evidence base that lets employers, researchers, and organizations like ours know whether the promise of equal employment opportunity is being kept. We urge the Commission to withdraw this proposed rule.

Respectfully submitted,

Kim Borman, Executive Director

Cathy Minehan, Co-Chair

Evelyn Murphy, Co-Chair

Boston Women's Workforce Council